Radical Transparency – Compliance Process and Violations
Pennsylvania has one of the most comprehensive and stringent regulatory environments for oil and gas operations in the country. CNX takes our duty as a responsible operator very seriously and we have implemented an Environmental Management System that is overseen by skilled environmental compliance experts in our Operational Excellence and our Environmental Strategy teams. These teams are dedicated to our environmental stewardship efforts and ensure compliance with environmental laws, regulations, and proactive improvement efforts.
The Department of Environmental Protection (DEP) and other regulatory agencies perform regular inspections of our sites. For example, there were 969 inspections performed on CNX sites by the PA DEP Office of Oil and Gas Management and recorded in the system over 2022–2023. That’s almost 1.5 per day on average, seven days a week, 365 days a year. During that time period, 943 of these inspections had no findings, 24 inspections were triggered because CNX had self-reported events, and two events were discovered by inspectors. To learn more about the number of violations the public sees and the correlation to the number of events that actually occurred, as well as the process CNX and the DEP follow, read this article “Challenging Environmental NGO/Media Optics with Facts and Data”.
The important thing to note is that if an event occurs, CNX self-reports to the DEP and quickly acts to remediate. CNX has been around this region for over 160 years – our team members were born here, live here, and desire to stay here. Our kids and parents breathe the same air and drink the same water as everyone else. It’s why we jumped at the chance to embrace Radical Transparency. It’s also the foundational reason why CNX works diligently with the regulatory community to self-report any incident, to efficiently abate any violation, and to always work with the agency to correct or improve the system.
We have a duty to respond in writing to NOVs we receive from the DEP and while we may disagree with the number of citations cited/interpretation of the law, CNX rarely takes the step to appeal the violations we receive, preferring to work instead with our regulators to resolve outstanding issues quickly and efficiently. Because when issues can be resolved without applying undue strain on DEP resources and taxpayer dollars that a costly appeal process entails, the outcome is better for all Pennsylvanians.
CNX is further committing to our Radical Transparency program by disclosing every Notice of Violation that we receive (listed below) and will continue to disclose the data for NOVs across federal, state, and local regulatory agencies on our ESG Performance Scorecard, along with the penalties we have paid, for our entire operating footprint.
Permit Number | Date | Project Name | Violation Description | Violation Type | Commentary & Current Status |
|---|---|---|---|---|---|
PA DEP | 6/17/2025 | RHL71 | CNX self-reported a release of 84 gallons of produced fluid to the ground. | Accidental Release | Act 2 clean-up is under way and upon completion a final report will be submitted to the DEP. |
PA DEP | 6/3/2025 | NV55HS | CNX self-reported a release of 4 gallons of produced fluid to the ground. | Accidental Release | Remediation efforts are complete. |
PA DEP | 5/9/2025 | MOR 40 | Failure to provide PUC notification within one hour after the discovery of a release. | Administrative | CNX did provide notification, but it was outside of the one-hour window. CNX updated emergency response procedures and training was provided to relevant personnel on 6/10/2025. Copies of the updated procedures and the training rosters were submitted to the PUC on 6/11/2025. Closure of the NOV is pending |
VA Department of Energy | 4/21/2025 | Y34K | CNX self-reported that a CBM pit liner was accidentally punctured, which compromised the integrity of the liner and resulted in a produced water spill (NOV received 4/23/2025). | Accidental Release | Remediation efforts are complete. Department inspection on 5/16/2025. NOV is CLOSED. |
PA DEP | 4/17/2025 | Scales 1 | Failure to post complete contact information. (NOV received 5/1/2025) | Administrative | Inherited violation from Apex acquisition. See Inheriting NOVs: Providing Context and Raising the Bar on Operational and Compliance Standards. CNX updated the contact information on 5/14/2025. |
PA DEP | 4/7/2025 | WFN12- | CNX self-reported a slope failure to the DEP. Accelerated erosion and sedimentation was noted near a stream crossing for a tributary of Templeton Fork stream. (NOV received 4/9/2025). | Erosion & Sediment Control | Temporary stabilization is completed and approved by the DEP. Permanent stabilization will occur after Permitting has acquired the relevant permits to perform the work. DEP inspection on 4/22/2025. NOV is ICS (In compliance with schedule). See further discussion on these type of events at Enabling Environmental Stewardship |
PA DEP | 3/28/2025 | POTTS TO WEITZ PIPELINES | Failure to submit the NOT prior to expiration of ESCGP (NOV received as VIOIC on 4/22/2025). | Administrative | Inherited violation from Apex acquisition. See Inheriting NOVs: Providing Context and Raising the Bar on Operational and Compliance Standards. NOV issued and immediately CLOSED on 4/22/2025. |
PA DEP | 2/27/2025 | Draftina Central Pad-31 | Agency inspection, directly after a rain event, discovered erosion and sedimentation below the soil stockpile and on the Northeast corner of the well pad. | Erosion & Sediment Control | The erosion downslope of the soil stockpile and on the Northeast corner of the well pad has been stabilized. E&S controls are in place. DEP compliance evaluation inspection on 4/10/2025. NOV is CLOSED. See further discussion on these type of events at Enabling Environmental Stewardship |
PA DEP | 2/18/2025 | Kiski River to BP6 Waterline | Failure to prevent erosion and sedimentation along the pipeline right-of-way, specifically noting erosion along the access road. | Erosion & Sediment Control | The erosion issues originated at a third party well site and were outside of the CNX LOD. CNX worked with the third party to re-grade and stabilize the area. E&S controls were installed. DEP compliance evaluation inspection on 3/14/2025. NOV is CLOSED. See further discussion on these type of events at Enabling Environmental Stewardship |
PA DEP | 2/14/2025 | Herminie Well Pad | Unreported release by Apex prior to the acquisition by CNX. Discovered and reported by CNX on 2/14/2025 (NOV issued 2/18/2025) | Accidental Release | Inherited violation from Apex acquisition. See Inheriting NOVs: Providing Context and Raising the Bar on Operational and Compliance Standards. Act 2 clean-up has been completed and submitted to the DEP. Awaiting final approval from the DEP. |
PA DEP | 1/31/2025 | Marian Laskowski 7 | Failure to plug a non-producing well (NOV received 3/14/25). | Production | Inherited violation from Apex acquisition. See Inheriting NOVs: Providing Context and Raising the Bar on Operational and Compliance Standards. On 4/1/2025, CNX submitted to the DEP a plan to return the well to Active Status. |
PA DEP | 1/31/2025 | Marian Laskowski 6 | Failure to plug non-producding well (NOV received 3/14/25). | Production | Inherited violation from Apex acquisition. See Inheriting NOVs: Providing Context and Raising the Bar on Operational and Compliance Standards. On 4/1/2025, CNX submitted to the DEP a plan to return the well to Active Status. |
PA DEP | 1/31/2025 | PF Eisaman South 43 | Unreported release by Apex prior to the acquisition by CNX. Discovered and reported by CNX on 1/31/25. | Accidental Release | Inherited violation from Apex acquisition. See Inheriting NOVs: Providing Context and Raising the Bar on Operational and Compliance Standards. Completed Act 2 remediation. DEP approved the Act 2 report |
PA DEP | 1/29/2025 | McQuay to Morris/Greene Trunkline | CNX self-reported a release of 30 gallons of produced fluid to the ground. (NOV received 1/29/2025). | Accidental Release | Remediation efforts are complete. DEP compliance evaluation inspection on 2/21/2025. NOV is CLOSED. |
PA DEP | 1/25/2025 | MOR42HS | CNX self-reported a release of 40 gallons of brine fluid to the ground. (NOV received on 1/27/2025). | Accidental Release | Remediation efforts are complete. DEP compliance evaluation inspection on 4/1/2025. NOV is CLOSED. |
PA DEP | 1/20/2025 | Norah Well Pad and Pipelines | Failure to submit the NOT prior to expiration of ESCGP (NOV received 1/31/25). | Administrative | Inherited violation from Apex acquisition. See Inheriting NOVs: Providing Context and Raising the Bar on Operational and Compliance Standards. DEP restoration inspection on 5/22/2025. NOT shall be approved and NOV is CLOSED. |
PA DEP | 1/14/2025 | Faulk-Fetur Pipeline | Failure to submit the NOT prior to expiration of ESCGP (NOV received 2/3/25). | Administrative | Inherited violation from Apex acquisition. See Inheriting NOVs: Providing Context and Raising the Bar on Operational and Compliance Standards. DEP follow-up inspection on 4/22/2025. NOV is CLOSED. |
PA DEP | 1/14/2025 | Stewart McIlvaine Pipeline | Failure to submit the NOT prior to expiration of ESCGP (NOV received 1/31/25). | Administrative | Inherited violation from Apex acquisition. See Inheriting NOVs: Providing Context and Raising the Bar on Operational and Compliance Standards. DEP follow-up inspection on 4/22/2025. NOV is CLOSED |
PA DEP | 1/14/2025 | McIlvaine to Spectra Pipeline | Failure to submit the NOT prior to expiration of ESCGP (NOV received 1/31/25). | Administrative | Inherited violation from Apex acquisition. See Inheriting NOVs: Providing Context and Raising the Bar on Operational and Compliance Standards, DEP follow-up inspection on 4/22/2025. NOV is CLOSED. |
PA DEP | 1/14/2025 | Steel to Faulk Pipeline | Failure to submit the NOT prior to expiration of ESCGP (NOV received 1/31/25). | Administrative | Inherited violation from Apex acquisition. See Inheriting NOVs: Providing Context and Raising the Bar on Operational and Compliance Standards. DEP follow-up inspection on 4/22/2025. NOV is CLOSED. |
PA DEP Air Quality | 1/13/2025 | Weitz South 20 Compressor Station | Agency inspection finding related to performance tests (NOV issued 1/28/25). | Administrative | Inherited violation from Apex acquisition. See Inheriting NOVs: Providing Context and Raising the Bar on Operational and Compliance Standards. |
PA DEP Air Quality | 1/13/2025 | Graham Well Pad | Agency inspection finding related to performance tests (NOV issued 2/3/25). | Administrative | Inherited violation from Apex acquisition. See Inheriting NOVs: Providing Context and Raising the Bar on Operational and Compliance Standards. |
CBM (Coal Bed Methane) – a type of gas well.
E&S (Erosion & Sedimentation) Controls – Controls installed to prevent earth movement caused by rain events / sheet flow.
ESCGP (Erosion & Sediment Control General Permit)- an earth disturbance permit associated with oil and gas activities.
ICS (In Compliance with Schedule) or ICP (In Compliance with Policy) – typically used to describe a pre-existing issue where the repairs are proceeding as planned.
LOD (Limit of Disturbance) – as per the permit, this refers to the outermost boundary of the area that can be disturbed.
NOT (Notice of Termination) – a document filed with the DEP to effectively terminate an existing earth disturbance permit. Filed after all planned earth disturbance is completed.
NOV (Notice of Violation) – issued by a regulatory agency to indicate a potential issue.
PUC (Public Utility Commission) – regulatory agency that oversees natural gas, pipeline, water, and wastewater services.
VIOIC (Violation Onsite Immediately Corrected) – regulatory agency identified
To find more information on compliance and enforcement or specific information on violations (when available) in these states please visit: Virginia Energy – Gas and Oil – Inspection and Enforcement, PADEP Oil and Gas Compliance – Report Extracts, WVDEP Office of Oil and Gas Enforcement Search, or Oil & Gas Inspections and Enforcement | Ohio Department of Natural Resources.
Test Your Knowledge
These photos capture erosion and sedimentation control events in southwestern Pennsylvania.
Which of these photographs received an Erosion & Sedimentation violation from the regulatory agency at a natural gas facility?
To learn more and test your compliance knowledge, hover on the photos.
NO
No. This area of unstabilized earth disturbance is adjacent to Route 18 in Washington County, Pennsylvania and discharges sediment filled water directly into Short Creek, a tributary of Ten Mile Creek.
NO
No. This is not a slip or slough associated with oil and gas activity. This environmental degradation is adjacent to a popular donut shop in southwestern Pennsylvania. This earth movement has continued to get worse since the adjacent bank was constructed in the past decade.
YES
Yes. This photo represents a condition described as a violation for erosion below a culvert. We struggle to see the evidence of accelerated erosion here.
YES
Yes. This photo is from an access road and illustrates a condition that was referenced to be a violation for erosional rutting that was stemming from a channel/ditch that is not controlled by CNX, discharging water from an unprotected culvert.
NO
No. This slip is part of a series that can be seen on the heavily travelled section of McMurray Road between the Upper Saint Clair police station and the roundabout that have gone unrepaired for months.
YES
Yes. This permit received an oil and gas violation. In this photo an area where erosion and sedimentation control fencing was not removed was described to be in violation, noting the overgrowth of vegetation. Ironically, one purpose of an erosion and sedimentation control permit is to ensure that the site, post-construction, has 70% vegetation established.
YES
Yes. This permit received a violation for failure to stabilize and evidence of a topsoil slough. This photo represents a condition outlined as a violation. CNX was onsite performing erosion inspections and addressing concerns which did not surpass erosion and sedimentation controls at any time. CNX believes it was in compliance with the conditions of the permit at the time of inspection and has contested this NOV.
NO
No. This photo was taken at a popular convenience store location in Greene County, Pennsylvania. The textbook rills and sloughing depicted here remain unaddressed as of the date of this publication.